1. Your privacy is important to OVO
OVO recognises the trust you’re placing in us through your dealings with us. We’re committed to protecting your personal information. Our policies comply with our obligations under applicable privacy laws and are intended to protect your privacy in respect of any personal information that you may provide to us.
In this policy, “OVO”, “we” and “us” means My Mobile Data Pty Ltd (ABN 84 168 943 986) trading as OVO Mobile.
2. What personal information OVO generally collects and why
We will only collect information about you that is reasonably necessary for us to perform our functions and activities. OVO collects information from customers, OVOPlay users and others in a number of different ways. These include when customers or others provide information to:
- subscribe to OVO services and activate an OVO SIM card, including for calls, SMS, MMS, data allowance, OVO Time or additional OVO content, or use, subscribe to or purchase content on OVOPlay;
- enter competitions, participate in OVO event activities, or subscribe to email or mobile newsletters, so that OVO can contact competition winners, and inform you about OVO events, activities and promotions (you have the option to opt out from receiving this information);
- use services offered on OVO’s website or apps (including OVOPlay) (the Site), including completing online surveys, setting up a membership on the Site and subscribing to OVO’s marketing communications,
(together, the Services).
When you become a registered user of any of the Services, we ask for:
- your name;
- a current and valid email address;
- in certain circumstances, your residential address, your telephone number and credit/debit card or PayPal details;
- in certain circumstances, information from a Government issued document that confirms your identity;
- in certain circumstances, demographic and preference information.
We collect this information in order to facilitate your use of our Services and the functionality provided by the Services, to help us improve our services and to carry out other activities specified in this policy. If you don’t provide us with this information, we may not be able to provide you with full access to all or part of the Services or functionality offered.
When you provide us with additional information to verify your identity, this information is not stored by OVO and is disclosed to and used exclusively to perform an identity check with our third party service provider.
If you’d like to remain anonymous or to use a pseudonym when dealing with us, we may be able to provide you with limited information or services. However, in many cases it won’t be possible for us to assist you with your specific needs given the nature of the facilities and services we offer.
We update the information we hold about you when you provide or we receive new information about you. In some circumstances we may need to ask you for documented evidence to update your personal information, especially in relation to your name or date of birth, as required by relevant law.
3. Other information we collect
We may also collect the following information from you through your devices in connection with the provision of our Services:
- log information: when you use the Services, we collect server logs, which may include information like the fully qualified domain name from which you accessed our Site, or alternatively, your IP address, the date and time you accessed each page on our Site, the URL of any webpage from which you accessed our Site (the referrer), cookies which track your visits to the Site and the web browser that you are using and the pages and content you accessed;
- contacts information: if you permit OVO to access the address book on your device when using the Services through the permission system used by your mobile platform, we may access and store names and contact information from your address book to facilitate social interactions through our Services and for other purposes described in this policy or at the time of consent or collection;
- device information: we may collect information about your mobile device, including, for example, the hardware model, brand, locale, operating system and version, software and file names and versions, preferred language, screen vertical and horizontal display size, unique device identifier, advertising identifiers, serial number, headphone connection, battery level and charging state, and mobile network information;
- device motion information: we may collect information based on your device’s motion, angle or position when using the Services which we use to infer certain conclusions about your current use of our Service including, for example, whether you may be stationary or moving, to determine if this is a suitable time to tell you about new content; or present advertising
- transaction information: we collect transaction details related to your use of our Services in order to maintain billing and provide service records, including the type of service requested, date and time the service was provided, and other related transaction details. Additionally, if someone uses a promotion or referral code of yours, we may associate your name with that person.
We request permission for OVO’s collection of precise location from your device per the permission system used by your mobile operating system. If you initially permit the collection of this information, you can later disable it by changing the location settings on your mobile device. However, this may limit your ability to use certain features of our Services.
4. Who collects the information
Personal information collected about individuals (as described above) in relation to the Services may be collected by or on behalf of OVO.
Information may also be collected by OVO on behalf of other people as set out in notices given to customers, or consents given by customers, at or prior to the time the personal information is collected. For example, if you choose to link, create, or sign into your OVO Dashboard with a social media service (e.g. Facebook), or if you engage with a separate app or website that uses our API (or whose API we use), we may receive information about you or your connections from that site or app.
If we receive personal information about you that we did not ask for either directly or through someone on our behalf, from someone other than you, and we determine that we could have collected this information from you had we asked for it, we will notify you, as soon as practicable, that we have collected your personal information. If we could not have collected this personal information, we will lawfully de-identify or destroy that personal information
5. Our use of personal information
We may use the information we collect about you in connection with the provision of our Services to:
- provide, maintain, and improve our Services, including, for example, to facilitate payments, send receipts, provide products and services you request (and send related information), develop new features, provide customer support to you, develop safety features, authenticate users, and send product updates and administrative messages;
- perform internal operations, including, for example, to prevent fraud and abuse of our Services; to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyse usage and activity trends; or
- personalise and improve the Services and to provide or recommend features, content, social connections, referrals and advertisements.
We may also sell or disclose to other parties, data we collect from you either with or without personally identifiable information you provide us. For example, we may provide this information to third parties to assist them to determine what advertising, promotional materials, products or services are likely to be of most interest to you and to assist merchants and other third parties to monitor general consumer trends in various areas. We may also modify or de-identify personal information (through encryption, aggregation or other de-identifying techniques) so that it is in a form from which you or others cannot be identified and sell or disclose such modified information to any person for any purpose, including to people or companies located outside of Australia.
6. How and where your personal information is stored
All personal information collected by OVO is held securely, in OVO's computer systems or in a database. This information is only made available to OVO staff on a 'need to know' basis or to other people as outlined in this policy, who have agreed to treat that information confidentially. The database is protected by a firewall as well as host-based security. These measures are designed to prevent your personal information being accessed by unauthorised personnel, lost or misused.
Your personal information may be transmitted over the Internet once it has been stored in the OVO database and may also be transferred across borders to foreign countries, where doing so is part of OVO’s business practices relating to the storage of data and where permitted by law. If OVO ever has a requirement to transmit such data over the Internet (for example, to make an off-site back up) it will be in encrypted form. You consent to us transmitting and storing your personal information overseas and agree that we are not required to ensure that any foreign-based service providers we use comply with privacy laws which may apply to OVO.
We will use all reasonable endeavours to keep your personal information in a secure environment, however, this security cannot be guaranteed due to the nature of the Internet. If you reasonably believe that there has been unauthorised use or disclosure of your personal information, please contact us (see below).
We will comply with all applicable mandatory data breach notification laws.
7. Unsubscribing from our email and SMS updates
By providing your email address to us, you expressly consent to receive emails from us, where permitted by law. We may use email to communicate with you, to send information that you have requested, or to send information about other products or services developed or provided by us or by third parties. If you have a subscription or other registration with us and don’t want to receive commercial email or other mail from us, please update this in the Personal info section of your OVO App or your OVO Dashboard. Please note that if you don’t want to receive legal notices from us, such as notices regarding this policy, those legal notices will still govern your use of the Site, and you are responsible for reviewing such legal notices for changes. We may receive a confirmation when you open an email from us if your computer supports this type of program. We use this confirmation to help us make emails more interesting and helpful and improve our service.
If you also provide your mobile number to us and opt in, we may send you periodic text messages through an automatic telephone dialling or messaging system. These may include marketing text messages, as well as transactional messages about features and updates to our Site or the Services. Standard text message and data rates will apply. You are not required to agree to receive text messages in order to use any of our apps or other services.
There is no fee for unsubscribing to our email and SMS notifications. Because of the way we maintain and distribute marketing information, your request may not take effect immediately, and you may continue to receive marketing information from us for a reasonable period.
You cannot refuse to receive information which we are required to provide you by law.
8. Disclosing and sharing your personal information
We will disclose personal information we have about you when:
- you agree to the disclosure including as set out in this policy;
- we use it for the purposes we collected it; or
- disclosure is required or authorised by law.
When you register for our Services and use our Services, you agree that, to the extent permitted by law, we may also disclose information about you to:
- related companies and affiliated entities that provide services or conduct data processing on our behalf, or for data centralisation and / or logistics purposes and for marketing purposes;
- third parties who provide services to OVO from time to time;
- third parties who provide a service to you or us that you requested through a partnership promotional offering made by a third party or us;
- vendors, consultants, marketing partners, and other service providers who need access to such information to carry out work on our behalf;
- third parties with whom you choose to let us share information, for example other apps or websites that integrate with our Services, or those with Services with which we integrate;
- government agencies as part of our statutory obligations;
- in response to a request for information by a competent authority if we believe disclosure is in accordance with, or is otherwise required by, any applicable law, regulation, or legal process;
- in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing or acquisition of all or a portion of our business by or into another company; and
- the general public if you submit content in a public forum, such as blog comments, social media posts, or other features of our Services that are viewable by the general public.
We may also disclose information about you:
- if we otherwise notify you and you consent to the sharing; and
- in an aggregated and/or anonymised form which cannot reasonably be used to identify you.
In addition to the purposes set out above, information may be used by OVO in connection with the management and security of the OVO business, and may be provided to law enforcement and government bodies, insurers, OVO staff and subcontractors, third parties who provide OVO with services from time to time and retailers for these purposes.
The Services may integrate with social sharing features and other related tools which let you share actions you take on our Services with other apps, sites, or media, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the social sharing service. Please refer to the privacy policies of those social sharing services for more information about how they handle the data you provide to or share through them.
You may elect to publicly post personally identifying or sensitive information about yourself in the course of using our Services. This could occur through the use of optional profile fields, or in interactions on public wikis and forums. Information that you voluntarily post in publicly visible parts of our Services is considered to be public, even if it would otherwise be considered to be personally identifying or sensitive. As such, it is not subject to the protocols listed here.
9. Deleting your personal information
Except as described below, we will retain personal information and other information we receive for as long as your registration or subscription is active or as needed to provide services through the Site. Notwithstanding anything to the contrary herein, we will retain and use the information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
If you terminate your registration or subscription with us, your profile, including any personal information, offers, purchases, or other information associated with your membership will be removed from the Site and eventually deleted from our servers. Because of the way we maintain the Site, such deletion may not be immediate, and residual copies of your profile information or posts may remain on backup media for up to ninety (90) days. Notwithstanding the foregoing, we will retain information as required by applicable law and we will not delete any information that has already been aggregated or anonymised.
To the extent we have already disclosed information about you to third parties before you delete your account, we cannot require such third parties to delete that information.
10. Your right to access your information
You have the right to access, update and correct your personal information held by us. We will take reasonable steps to ensure that personal information is up-to-date, accurate and complete and to correct any out-of-date, inaccurate or incomplete personal information if you request us to do so, where required by law, within a reasonable period.
If you wish to access, update or correct your personal information held by us, please contact us (email@example.com).
We may withhold or refuse you access to your personal information if we are legally authorised to do so or where its disclosure to you is restricted by law, is the subject of legal action, or may compromise the privacy of another person. We will give you written reasons explaining why we have refused access, or refused access in the form you have requested unless it would be unreasonable to do so, having regard to the reasons for our refusal.
We may charge you a reasonable fee to access your information as permitted by applicable law.
11. Information collected from children
We do not knowingly collect personal information from children under the age of 18 without parental or guardian consent. If we learn that we have inadvertently obtained such information, we will promptly delete the information. If you believe that a child has provided us with personally identifiable information without the consent of his or her parent or guardian, please contact us at 135 686 or using the email or chat tools on our website.
13. Further information regarding this policy
If you would like further information relating to the Privacy Act 1988 and the Australian Privacy Principles, please visit www.oaic.gov.au.
Please contact OVO's Privacy Officer if you believe:
- someone has gained access to your personal information by mistake;
- we have breached our privacy obligations or your privacy rights in any way; or